Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 154 Filed 12/15/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS
LLC,
Plaintiff,
v. Civil Action No. 04-1258-SLR
THE TRIZETTO GROUP, INC.
Defendant.
DECLARATION OF KAREN LAMPE
IN SUPPORT OF THE TRIZETTO GROUP, INC.'S
MOTION FOR SUMMARY JUDGMENT OF NON-INFRINGEMENT

Case 1 :04-cv-01258-SLR Document 154 Filed 12/15/2005 Page 2 of 4
I, Karen Lampe, declare as follows:
1. I am employed by The TriZetto Group, Inc. ("T1iZetto") as a Business Analysis
Specialist in Product Development for TriZetto’s ClaimFacts product. I submit this declaration
in support of T1iZetto's motion for summary judgment of non-infringement. I have personal
knowledge of the facts set forth herein and if called upon to do so, Icould and would testify
competently hereto.
2. ClaimFacts is a software product used by insurers, health maintenance
organizations (HMOs), preferred provider organizations (PPOs), and other health benefit
providers to process claims for medical services. ClaimFacts can perform a wide range of claims
processing functions, including clinical editing. The clinical editing function of ClaimFacts is
performed by an optional sub-system called ClinicaLogic.
3. Clinical editing involves checking and editing the medical procedure codes on a
medical claim in accordance with expert—derived clinical criteria. For a further description of
clinical editing, see the Declaration of Craig P. Luftig, filed herewith, at paragraph 3.
4. The clinical criteria used by the ClinicaLogic module of ClaimFacts are found in
the ClinicaLogic database. Each clinical criterion is contained in a separate clinical editing
record, called a "CE Record," in the database.
5. ClinicaLogic provides an interface that the customer can use to modify clinical
criteria (CE Records) in the database as desired. The customer can delete existing CE Records
from the database or add new CE Records to the database. The customer can also change
various terms within a CE Record, including removing or deactivating edits in the record.
6. ClinicaLogic does not check to see if a received claim has more than one code in
order to perform clinical editing. ClinicaLogic will perform clinical editing (including multiple-
code edits, if applicable) on all claims received, regardless of the number of codes present on the
claim. In the process of clinical editing, ClinicaLogic will examine any codes submitted on
earlier claims for the same patient together with the code or codes from the current claim.
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Case 1:04-cv-01258-SLR Document 154 Filed 12/15/2005 Page 3 of 4
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
This declaration was executed this 14th day of cember, 2005, at Union, New Jersey.
Karen Lamp!
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3

Case 1:04-cv-01258-SLR Document 154 Filed 12/15/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I, Jack B. Blumenfeld, hereby certify that on December 15, 2005 I electronically
tiled Declaration of Karen Lampe in Support of the TriZetto Group, Inc.’s Motion for Summary
Judgment of Non-Infringement with the Clerk of the Court using CM/ECF, which will send
notification of such filing(s) to the following:
Thomas J. Allingham, II
Skadden, Arps, Slate, Meagher & Flom LLP
I also certify that copies were caused to be served on December 15, 2005 upon the
following in the manner indicated:
BY HAND
Thomas J. Allingham, II
Skadden, Arps, Slate, Meagher & Flom LLP
One Rodney Square
P.O. Box 636
Wilmington, DE 19899
BY EMAIL
Jeffrey G. Randall
Skadden, Arps, Slate, Meagher & Flom LLP
525 University Avenue
Suite 1 100
Palo Alto, CA 94301]
/s/ Jack B. Blumenfeld (#1014)
Morris, Nichols, Arsht & Tunnell
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899
(302) 658-9200
[email protected]